How have courts interpreted the doctrine of contribution for costs and attorney fees?

The court in Lindsey discerned three elements of the doctrine: "(1) without the litigation there would have been no recovery; (2) the recovery was an available fund out of which the beneficiaries of the litigation would be paid; and (3) the applicant seeking contribution in respect to costs and attorney fees was the sole 'active litigant' and as such obtained the recovery that provided the fund." (Lindsey v. County of Los Angeles, supra, 109 Cal.App.3d at p. 936, 167 Cal.Rptr. 527.)